Gray v. Hattfield
3:25-cv-00316
| N.D. Ind. | Jun 27, 2025Background
- Plaintiff Santana J. Gray, an incarcerated individual, alleges he was sprayed with O/C spray by Officer Hattfield "for no reason" while in custody on June 14, 2024.
- After being sprayed, Mr. Gray was taken to medical with shackles that were allegedly too tight, requested a breathing treatment, and was told to shower first, but refused because he was still handcuffed.
- Despite requesting that Sergeant Gill remove the handcuffs so he could decontaminate, she refused; Gray claims this exacerbated his symptoms and made his asthma worse.
- Medical staff examined Gray but, according to his allegations, denied further treatment by not checking his vitals before directing return to his cell, where he suffered continued effects from the O/C spray.
- Mr. Gray sued Officer Hattfield (for excessive force), Sgt. Gill, and "Medical Staff" (for deliberate indifference to medical needs) under 42 U.S.C. § 1983.
- The court screened the complaint as required by 28 U.S.C. § 1915A to determine if any claims could lawfully proceed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force/O/C spray | Hattfield sprayed Gray without justification | Not yet briefed, but force may have been justified | Sufficient factual basis for Eighth Amendment claim vs. Hattfield |
| Deliberate indifference - medical | Sgt. Gill and Medical Staff were indifferent after O/C spray | Not yet briefed; Gill did not deny shower or care | No plausible claim against Sgt. Gill or "Medical Staff" |
| Sufficiency of allegations/pleading | Named "Medical Staff" & collective allegations | Lack of specificity; improper group claims | Claims against "Medical Staff" dismissed |
| Responsibility for medical staff's conduct | Gill responsible for medical staff's actions | Division of labor: not Gill's job | No liability for Sgt. Gill for medical staff actions |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard for facial plausibility)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility requirement for complaints)
- Erickson v. Pardus, 551 U.S. 89 (liberal construction for pro se pleadings)
- Whitley v. Albers, 475 U.S. 312 (standard for excessive force in prisons)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard)
- Soto v. Dickey, 744 F.2d 1260 (need for prisoner compliance with orders)